Where Art Thou? In Tax Court Battling Over Technical Issues and Valuation

Colorful balconies in Russian apartment block. Fragment of modern residential flat apartment building exterior. Part of city real estate property and condo architecture. Colorful balconies in Russian apartment block. Fragment of modern residential flat apartment building exterior. Part of city real estate property and condo architecture.

Where Art Thou? In Tax Court Battling Over Technical Issues and Valuation

June 22, 2026

TAX NOTES FEDERAL

The “compliance campaign” centered on charitable donations continues, with the IRS now focusing more attention on art.  This article by Partner Hale Sheppard provides an overview of charitable gifts, summarizes the evolution of government actions, analyzes two pending Tax Court cases involving fine art, identifies IRS settlement offers for conservation easements, explains why potential reasons for settling easement cases do not apply to art donations, and questions whether the IRS will have any success if it tries to rely on old techniques in new contexts.

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Hale E. Sheppard

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Atlanta, United States

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